Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
HC determined that subsequent or retrospective cancellation of supplier registrations does not invalidate a taxpayer's request for voluntary GST deregistration, provided the supplies were obtained from validly registered vendors who had paid applicable taxes at the time of transaction. The petitioner was granted three weeks to submit documentation proving the legitimacy of input supplies and corresponding tax payments. The revenue authorities must evaluate the voluntary cancellation application based on verification of these submissions, focusing on the registration status of suppliers at the time of actual transactions rather than their current status. The matter was disposed with directions for administrative review of the deregistration request.
HC determined that subsequent or retrospective cancellation of supplier registrations does not invalidate a taxpayer's request for voluntary GST deregistration, provided the supplies were obtained from validly registered vendors who had paid applicable taxes at the time of transaction. The petitioner was granted three weeks to submit documentation proving the legitimacy of input supplies and corresponding tax payments. The revenue authorities must evaluate the voluntary cancellation application based on verification of these submissions, focusing on the registration status of suppliers at the time of actual transactions rather than their current status. The matter was disposed with directions for administrative review of the deregistration request.
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